PVCS Privacy Policy

Primary Vision Care Services, Inc. understands that personal information made
available to PVCS when you purchase services and products from us is trusted and
private. PVCS safeguards that trust and privacy by keeping nonpublic personal
information about you in a confidential environment and using that information
in accordance with this Privacy Policy.

I. Purpose

The purpose of this policy is to describe how we protect the privacy of
information, and why it is necessary to use this information to provide high
quality services and materials to you. This notice tells you what types of
information we may need, what types of information we need to share with others,
and the security measures we use, as well as your right to ask PVCS not to share
personal information about you with other companies for marketing purposes.

Please keep this notice where it is available to you. If you are an employer,
please provide a copy of this information to your employees.

II. Scope/Policy

Primary Vision Care Services will not disclose any private information about a
member collected or received in connection with a vision care transaction unless
the disclosure is permitted or required by law.

Primary Vision Care Services will disclose private information under the
following conditions:

To the member or the member's legal representative or guardian, upon
presentation to PVCS of a valid Social Security or Member Identification number

With the written authorization of the member, or the member's legal
representative or guardian, provided the authorization is dated, signed by the
member or the member's legal guardian; and is within one (1) year or less prior
to the date a disclosure is sought

To a group policyholder for the purpose of reporting claims experience or
conducting an audit of PVCS’ operations or services, provided the information
disclosed is reasonably necessary for the group policyholder to conduct the
review or audit

To a medical care institution or medical professional for the purpose of
verifying coverage or benefits; informing an individual of a medical problem of
which the individual may not be aware; or conducting an operations or services
audit to verify the members treated by the medical professional or at the
medical care institution; provided only such information is disclosed as is
reasonably necessary to accomplish the foregoing purposes; or

To an insurance institution, health care organization, or self-insurer, provided
the information disclosed is limited to that which is reasonably necessary to
detect or prevent criminal activity, fraud, material misrepresentation or
material nondisclosure in connection with insurance transactions; or for either
the disclosing or receiving entity to perform its function in connection with an
insurance transaction involving the member;

To an insurance or healthcare regulatory authority; or

To a law enforcement or other governmental authority to protect the interests of
PVCS in preventing or prosecuting the perpetration of fraud upon it; or if PVCS
reasonably believes that illegal activities have been conducted by the member;

For the purpose of conducting actuarial or research studies, provided no member
may be identified in any actuarial or research report; materials allowing the
member to be identified are returned or destroyed as soon as they are no longer
needed; and the actuarial or research organization agrees not to disclose the
information unless the disclosure would otherwise be permitted by this section
if made by an insurance institution, agent or insurance support organization; or

To an internal or external professional peer review organization for the purpose
of reviewing the service or conduct of a medical care institution or provider;
or

To a governmental authority for the purpose of determining the member’s
eligibility for vision or health benefits for which the governmental authority
may be liable; or

In response to a valid administrative or judicial order, including a search
warrant or subpoena; or

To a health maintenance organization, health plan, or insurer, when PVCS is
acting as a subcontractor to that organization, and the member is covered by
PVCS pursuant to his/her enrollment in that organization. In that circumstance,
all private information maintained by PVCS by virtue of the contract with the
organization will be made available to the organization; or

Otherwise permitted or required by law.

In addition to those circumstances described above, eligibility information will
be provided in the following circumstances where permitted or required by law:

To a member doctor, a member, a member's current spouse, a member's eligible
dependent, or the legal guardian of an eligible dependent, upon presentation to
PVCS of a member's valid Social Security or identification number;

To a person who accesses the PVCS Internet web page (www.pvcs-usa.com) and
provides a valid Social Security or identification number.

III. Procedure

All PVCS employees, upon employment, agree to abide by the policy and procedure
of "Confidentiality of Information" which details the importance of
confidentiality of medical records, personal information, insurance claims and
other materials. A violation of this policy may lead to disciplinary action up
to and including dismissal from employment.

Any patient specific information or medical record will be considered
confidential and will be shared only with those parties who have the authority
to receive such information.

If disclosure is required through a court order or subpoena, the order or
subpoena will first be reviewed by the PVCS Legal Counsel to determine the
legitimacy of the order, the purpose for the disclosure, and limitations on the
information disclosed.

All patient specific medical information will be stored for the appropriate
length of time as required by legal statutes and company policy, in files that
are secure and made accessible only for the purposes stated above.

System stored patient specific medical and personal information will be
protected through system security measures designed to protect against access by
unauthorized staff.

The PVCS Provider Guide states that the contracted doctor’s offices shall
maintain the integrity and confidentiality of private information in the record
against loss, defacement, tampering or use by unauthorized persons. The
contracted doctor’s office shall maintain a policy of confidentiality regarding
patient medical record information.

Should PVCS becomes aware of a confidentiality violation by a member doctor,
either through an on-site visit or through a complaint/grievance, the Quality
Assurance Committee and PVCS staff will determine the proper steps needed to
restore confidentiality. The PVCS Board of Directors will be consulted if the
violation was perpetrated through an employee.

This policy shall be provided to any member, group, or member doctor upon
request.

IV. Changes to Our Privacy Policy

From time to time, it may be necessary to amend this privacy policy. Primary
Vision Care Services reserves the right to modify or supplement this Privacy
Policy at any time. If we make material changes, we will provide current
customers with a revised notice that describes our new practices on an annual
basis.